RULE OF LAW & ITS APPLICATION IN INDIA



Democracy as a system of Government has been criticized by many great scholars. Some, like Winston Churchill have called it “the worst form of Government”. This is just a reflection on the fact that Democracy is felt by some to be an instrument that can be easily exploited. On the other hand, many scholars and political thinkers like the Former President of USA, Abraham Lincoln have famously described Democracy as “a government of the people, for the people and by the people”. The betterment of this concept would surely make the social order and increase the contentment in people. Furthermore, this would help achieve the basic spirit of constitution that strives to achieve the maximum benefit for the people.

One of the major instrumentalities for the betterment of Democracy is the concept of Rule of Law. Rule of Law is one of the most significant political ideals of any nation. The essence of Rule of law can be understood best in the words of Tom Bingham, who stated that all people and authorities within the State, whether public or private, must be bound by and subject to the benefit of the laws publicly and in the same manner.[1]

Rule of law basically embodies the concept of supremacy of law. It may be considered as an absolute Fundamental Necessity for a disciplined and organized society.[2]

Any state that is committed to democracy will give utmost important to Rule of Law. Stability at local, national and even international levels is directly related to Rule of Law. Rule of Law ensures the notion that the Constitution governs the actions taken by the State.[3] Rule of law implies that every person must be subject to the Law, including the lawmakers, law enforcement officials and even Judges in courts.[4]

If we turn to the history of lawmaking all around the world, we can easily find the mention of the concept of supremacy of law. Right from the to the Ancient Romans during the formation of the first republic, to medieval thinkers like Hobbs, Locke and Rousseau who championed the concept of Rule of Law through the Social Contract Theory, it has always been an integral part of lawmaking. Justice Coke, who is considered as the originator of Rule of Law, asserted the pre-eminence of the common law in England, even over the authority of the crown. It was AV Dicey, however, who revived and discussed the term in such a way that everyone could understand it.[5]

One of the foremost authorities on the doctrine of Rule of Law is A.V. Dicey. In 1885, Dicey pointed out that Rule of Law means the absolute supremacy of law and excludes the existence of any arbitrariness or wide discretionary powers on part of the Government. He asserted that wherever there was discretionary power, there was room for arbitrariness which could hamper the legal freedom of the society.[6]

Dicey also attributed the concept of “equality before law and equal subjection to the law of the land”, and even criticized the French system called droit administratif, of having separate courts to decide cases between the Government and the citizens.[7] He further went on to say that the concept of Administrative law was non-existent in Britain. In doing so, he ignored the privileges and immunities of the crown and even statutes that conferred special powers over the executive.[8] However, by 1915, after a few famous cases regarding administrative law, he himself became aware of the emergence of Administrative Law. He propounded the principle of complete absence of discretionary powers and inequality, which in today’s day and age cannot be fully implemented. [9]

Rule of Law essentially implies that the executive must act under the law and not by its own decree. This principle was always followed in common law countries, and still serves as the basis for judicial review of executive actions. Thus, it can be said that Administrative Law does not infringe the Rule of Law, but on the other hand, promotes it.[10]

Since Britain followed the Dicean theory for a very long time, Administrative Law did not develop into a satisfactory system there. It is widely believed that, mere judicial review of executive action is not enough to effectively control the Administration and some principles from the French droit administrative should be incorporated into common law countries. This is now being implemented in many common law countries and efforts are being made to improve the system.[11]

In spite of the flaws in Dicey’s theory of Rule of Law, the three principles[12] propunded by him are celebrated even today:

1.     Absence on arbitrary power on the part of the government.

2.     Equal subjection of all men to the law of the land

3.     Predominance of legal spirit.

THE APPLICATION OF RULE OF LAW IN INDIA

In India, thinkers and philosophers have often attributed the rule of law to be supreme and above the kings or rulers. Mentions have been made in Upanishads about Law being the King of Kings. Even, Chanakya in the Arthashastra talks about how the King should be governed by law.[13] The concept of Rule of Law in India has undergone many changes. The pre-independence era saw the British prove not only the defects in the concept, but also how its ideals were good on the paper only. Post-independence, the situation is not the same.

Dicey always maintained that the British do not need any form of Administrative Law or written law to keep a check on the functions of the Government. He maintained that the natural law would be enough to ensure the absence of arbitrariness on part of the executive. India also follows the same concept of natural law, but also has written laws to keep a check on the executive.[14]

The Constitution of India is what makes India a country governed by the concept of supremacy of law. All the functionaries of the Government, i.e., the Legislature, Executive and Judiciary, derive their authority from the Constitution of India. The Constitution does not express the concept of Rule of Law directly or explicitly, but does include its ideals implicitly, under various articles and provisions.[15]

One of the major principles of Rule of Law is that the Government does not possess any arbitrary power. This means that the Law is supreme and no one is above the law. The is followed in the Indian Constitution as well. For example, Article 13(1)[16] provides that any law made by the Parliament has to be in line with the Constitutional provisions, otherwise it can be declared as null and void. Article 21[17] on the other hand clearly states that no one can be deprived of their right to life and personal liberty except according to procedure established by law. This provides a further check on the lawmakers of the country.

The second main ideal of Rule of Law, according to Dicey, is the equal subjection of people to the law of the land. This has been inculcated in Article 14[18], which provides that there can be no discrimination against any person on the basis of sex, religion, race or place of birth. This means that the law considers everyone to be equal and provides everyone with equal protection, except in certain cases.

The doctrine of separation of powers, although having no place in the strict sense in the Constitution of India, is also implied. This has been appreciated by the courts as well. In Re Delhi Laws Act case[19], it was held that the functions of the Legislature, Executive and Judiciary have been clearly earmarked and do not overlap. Later, in the landmark case of Kesavananda Bharati[20], the doctrine of separation of powers was termed to be part of the basic structure of the Constitution and cannot be destroyed or changed by any amendment. This just goes on to show the predominance of Legal Spirit in the country. Thus, the Constitution fulfils all the criteria set out by Dicey to be a country that follows the concept of Rule of Law.

The three points set out are not the only provisions following the concept of Rule of Law. The view in Bachan Singh v. State of Punjab[21] can be reiterated to best explain this. It was stated that Rule of Law can be found in the entire Constitution and is, thus, one of its basic features.

PRACTICAL APPLICATION OF RULE OF LAW IN INDIA

Even though Dicey’s criteria of Rule of Law are met by the Constitution of India, it must be pointed out that contrary to Dicey’s view, India does have a foundation of Administrative Law to govern the actions of the Government. Chapter I of Part V of the Constitution of India[22], governs all the aspects of the Executive. In addition to this, there exist various laws to further ensure compliance.

In reality though, India does not fair very well when it comes to the rampancy of corruption in the country. India was ranked a very low 81st on the Corruption Perception Index, 2017.[23] Even according to the World Justice Project’s Rule of Law index, which measures adherence to the Rule of Law by various countries across the world, India ranks a lowly 62 out of 113 countries measured.[24] The parameters for this report included - Constraints on Government Powers, Absence of Corruption, Openness of Government, Fundamental Rights and its applications, Order and Security, Enforcement of Regulation, Existence of Civil Justice and Criminal Justice.[25]

Even though the situation in India regarding Rule of Law might not be very reassuring, as compared to other countries across the world, the situation is definitely improving. The ranks achieved by India in the reports mentioned above[26] has improved by a great extent over the years. In addition to this, the judiciary in India is considered to be the best and the strongest in the world. The Supreme Court of India in its various judgments has given the utmost importance to the concept of Rule of Law.

In the celebrated case of ADM Jabalpur v. S. Shukla[27], the misuse of the Government’s power to impose emergency and deprive people of their fundamental rights was considered. The dissenting judgment given by Khanna, J., pointed out that the absence of Article 21 does not mean that the Government can deprive a person of their right to life and liberty, unless it is according to procedure established by law.

Later in the case of Chief Settlement Commr., Punjab, v. Om Prakash[28], it was held that Rule of Law is one of the most important features of the Constitution of India and allows courts to test all administrative actions according to the standard of legality. The case of Satvant Singh Sahwney v. D. Ramarathanana[29] pointed out that every executive action that is arbitrary in nature must be supported by a legislative authority.

Thus, we can see that even if rule of law may not be perceived to be strictly followed in the country, some form of it will always persist. The courts have time and again ensured that Rule of Law in maintained in the country. In Maneka Gandhi v. Union of India[30] and Union of India v. Raghubir Singh[31], the Supreme Court of India has ensured that no arbitrary action of the Government cannot, in any manner, infringe the rights of the citizens.

Even if we just look at the Constitution of India, and not the decisions of the courts, there exist many provisions for the protection of Rule of Law. While there have been many major instances of corruption on part of Government Agencies, they have been brought out only because of the action of various constitutional bodies like the Central Vigilance Commission and the Comptroller and Auditor General against the perpetrators.[32] Thus, Rule of Law is adequately protected and maintained in the country, even though it might not seem like it.

CONCLUSION

The Constituent Assembly of India drafted a Constitution that established a country that is governed by the law, and not by people. Every person in India is subject to the same laws unless the law itself says so otherwise. This was thought to be an impossible feat, by political thinkers and philosophers all over the world.

In addition to this, the courts of law have also strengthened the mechanism of Rule of Law in the country. Each and every time a question of arbitrariness has come up before any court of law in India, the letter of the law has always prevailed. In doing so, the courts ensure smooth delivery of justice to all citizens.

There may be many problems in the law that have led to huge scams recently, but the predominance of legal spirit has effectively and efficiently brought justice to the citizens as well as the perpetrators for all the harm done. Thus, it can be safely said that Rule of Law is not only followed in India, but it is upheld as one of the most important ideals in its Constitution.




[1] Tom Bingham, The Rule of Law (London: Allen Lane, 2010) p. 8

[2] Jain, M. and Jain, S. (2013). Principles of Administrative Law. 6th ed. LexisNexis, p.13.

[3] Blandine Kriegel, The State and the Rule of Law (Princeton University Press, 1995), passim.

[4] Hobson, Charles. The Great Chief Justice: John Marshall and the Rule of Law, p. 57 (University Press of Kansas, 1996.

[5] Mahajan, V. (2010). Jurisprudence and legal theory. 5th ed. Lucknow: Eastern Book Co.

[6] Supra, note 2.

[7] THE LAW OF THE CONSTITUTION 198 (8th Ed.)

[8] Supra, note 2.

[9] Jain, M. and Jain, S. (2013). Principles of Administrative Law. 6th ed. LexisNexis, p.14.

[10] Harry W. Jones, The Rule Of Law And The Welfare State, 58 Col LR 143 (1958)

[11] Jain, M. and Jain, S. (2013). Principles of Administrative Law. 6th ed. LexisNexis, p.15.

[12] A.V Dicey, Introduction to the study of Law of the constitution, 8th Edition (Macmillan, London 1914).

[13] Mahajan, V. (2010). Jurisprudence and legal theory. 5th ed. Lucknow: Eastern Book Co.

[14] Jain, M. and Jain, S. (2013). Principles of Administrative Law. 6th ed. LexisNexis, p.16.

[15] Jain, M. (2017). Indian Constitutional Law. 7th ed. LexisNexis.

[16] Article 13(1), The Constitution of India, 1949

[17] Article 14, The Constitution of India, 1949

[18] Article 21, The Constitution of India, 1949

[19] In Re Delhi Laws Act Case, AIR 1951 SC 332

[20] Kesavananda Bharati v. State of Kerala, AIR 1973 SC 1461

[21] Bachan Singh v. State of Punjab, AIR 1982 SC 1325

[22] Chapter I, Part V, Constitution of India, 1949

[23] E.V., T. (2018). Corruption Perceptions Index 2017. [online] www.transparency.org. Available at: https://www.transparency.org/news/feature/corruption_perceptions_index_2017#table [Accessed 16 Jul. 2018].

[24] World Justice Project (2018). Rule of Law Index 2017-2018. Rule of Law Index. [online] World Justice Project. Available at: https://worldjusticeproject.org/sites/default/files/documents/WJP-ROLI-2018-June-Online-Edition_0.pdf [Accessed 16 Jul. 2018].

[25] World Justice Project. (2018). WJP Rule of Law Index 2017–2018. [online] Available at: https://worldjusticeproject.org/our-work/wjp-rule-law-index/wjp-rule-law-index-2017%E2%80%932018 [Accessed 16 Jul. 2018].

[26] Supra, notes 23 and 24.

[27] ADM Jabalpur v. S. Shukla, SC 1976 AIR 1207

[28] Chief Settlement Commr., Punjab, v. Om Prakash, SC 1969 AIR 33

[29] Satvant Singh Sahwney v. D. Ramarathanana, AIR 1967 SC 1836

[30] Maneka Gandhi v. Union of India, AIR 1978 SC 597

[31] Union of India v. Raghubir Singh, 1989 AIR 1933

[32] Kumar, B. (2014). Rule of Law in India. [online] Lawctopus. Available at: https://www.lawctopus.com/academike/rule-of-law-in-india/ [Accessed 20 Jul. 2018].

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